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Abstract: 

Thirty-two-year-old Kaylan Bell appealed his federal civil commitment under the Adam Walsh Act arguing that his repeated exhibitionism to children does not qualify him as a “sexually dangerous person.” The 4th Circuit upheld a district court ruling sustaining Bell’s civil commitment; this article examines the court’s reasoning, which rejected the plaintiff’s claim that his behavior, limited to exhibitionism and masturbation, did not warrant civil confinement.

Keywords: U.S. v. Bell

Affiliations:  1: Executive Editor.